Aerial Application of Isocycloseram: Crop Permissions, Runoff Rules, and Compliance Responsibility
Stay Updated on ESA Restrictions
Abbreviations
EPA — Environmental Protection Agency
ESA — Endangered Species Act
PULA — Pesticide Use Limitation Area
BLT — Bulletins Live! Two
ULV — Ultra-Low Volume
DSD — Droplet Size Distribution
Highlights
- Aerial application of Isocycloseram is not permitted for all crops — only specifically allowed crops may be treated from the air.
- Ultra-low-volume aerial application (<2 GPA) is prohibited nationwide.
- Even when applying by air, TWO runoff mitigation points are mandatory, unless the field meets a runoff exemption condition.
- Drift buffers (300 ft for aerial) are mandatory, but can be reduced using EPA’s Mitigation Menu options.
- BLT lookup is required within 6 months prior to or on the day of application.
Crop-Specific Aerial Use Permissions
Based on the product labels:
Aerial application is allowed for these crops:
- Cotton
- Potato
- Soybean
- Corn (only for specific labeled formulations)
Some labels specify:
“Aerial application is prohibited for all uses except Cotton, Potato, and Soybean.”
Other labels specify:
“Aerial application is prohibited for all uses except Corn, Cotton, Potato, and Soybean.”
And in New York:
“DO NOT apply by air in New York state.”
Aerial application is prohibited for:
- vegetables (except where label allows per specific formulations)
- fruit crops (except where label allows)
- tree nuts (except where label allows)
- turf and ornamentals
- residential areas
- greenhouse applications
- plants grown for transplant
Applicators should never assume aerial application is approved — it must be verified directly from the product label.
ULV Aerial Is Prohibited
Regardless of crop:
“Ultra-low volume (ULV) applications, spray volumes <2 gallons per acre, are prohibited.”
Drift Requirements for Aerial Application
Mandatory label conditions include:
- Sustained wind speeds between 3–15 mph
- No temperature inversions
- Nozzle selection delivering medium or coarser droplets (ASABE S641)
- Boom length relative to aircraft span or rotor diameter (Per Mitigation Menu, 50% boom length reduction allows for up to 65% drift buffer reduction)
- Swath displacement upwind based on wind speed conditions
- Height ≤10’ above canopy unless necessary for safety
- 300-ft wind-directional ecological buffer to non-managed areas
However, applicators can use mitigation options to reduce or remove buffer requirements, if compliant, such as:
- coarser droplet size
- lower boom height
- downwind windbreak
- reduced application rate
- higher relative humidity
- boom length reduction
The Critical Issue: Runoff Mitigation for Aerial Applicators
Aerial applicators often focus on drift but may underestimate the runoff compliance burden.
Here is the rule:
TWO runoff/erosion mitigation points are required outside PULAs for all crops listed on the label unless the field qualifies for an exemption.
This is true EVEN IF:
- there is no soil incorporation
- the field appears dry
- there are no nearby waterways
Runoff/Erosion compliance is required and the applicators responsibility
Related: How to Determine if Runoff Mitigation Is Required
Applicator Responsibility and Defensibility
The EPA guidance states:
“Pesticide users will need to plan their pesticide applications in advance to determine whether they are subject to runoff/erosion mitigation.”
This means:
✔ The applicator must determine if runoff points are required.
✔ The applicator must determine if the field qualifies for an exemption from runoff/erosion.
✔ The applicator must be prepared to defend that determination in audit or investigation.
This requires:
- documented BLT lookup
- documented runoff determination
- documented mitigation measures or documented exemption justification
If it isn’t documented, it didn’t happen.
EPA Official Decision Sequence for Runoff
Step 1: Plan for the season
Identify expected crops and products.
Step 2: Determine whether runoff points are required
Does the label or BLT require runoff mitigation?
If NO → no runoff mitigation needed.
If YES → proceed to Step 3.
Step 3: Does the field qualify for exemption?
If ANY of the following conditions are true:
- perimeter berm
- tailwater return
- controlled subsurface drainage
- soil injection
- tree injection
- subsurface chemigation
- spot treatment under 1,000 sq ft
- treated area <1/10 acre
- ONLY managed areas downwind for the full buffer length
Then:
“No additional runoff/erosion mitigation needed.”
If NONE of the above apply → runoff points must be achieved.
Practical Example for Aerial Applicators
Aerial applicator receives a request to treat a cotton field.
They must document:
- BLT lookup
- Whether the field is inside a PULA
- If inside a PULA — how many points required (could be 4 or 6)
- If outside a PULA — label still requires 2 points of runoff/erosion mitigation
- Runoff exemption determination - if the field is exempt, must document the reason
- Mitigation used or justification of exemption
Acre Blitz enables applicators to prove:
- that they checked BLT
- that they checked PULA boundaries
- that they verified whether points were required
- that mitigation measures were applied
- and that data is stored for audit defense
👉 Integrate the PULA Check API into your platform
Final Message to Applicators
Aerial application of Isocycloseram comes with both unique crop level restrictions and runoff/erosion mitigation responsibilities.
You must:
✔ confirm crop eligibility
✔ comply with wind, height, and nozzle requirements
✔ maintain drift buffers (or formally mitigate them)
✔ verify runoff mitigation requirements
✔ document the runoff decision
✔ record mitigation actions or exemption justification
✔ log the BLT lookup
Acre Blitz exists to support that compliance reality and to ensure that when state regulators ask:
“Show us how you determined compliance with all applicable ESA requirements for this application?”
— you have the answer.
